Researching Predicate Devices for Your 510(k) By Leslie Oberhaus & Marlene Bobka You’re developing an infrared thermometer and you’re not even sure how it’s classified by FDA. How can you determine the classification and predicates, see the disclosable portions of earlier 510(k)s, examine user manuals, identify review difficulties and see the Substantial Equivalence letters, including the dates of 510(k) submission and decision? The answers to these questions aren’t on FDA’s website, but FDA’s files of 510(k) submissions hold all of this information and more -- and much of this documentation is disclosable under the Freedom of Information Act (FOIA). The problem? A request using FOIA to obtain a predicate 510(k) can take up to 3 years to be answered – and you can’t wait that long for the information you need to get your medical device to market. The solution? Go to www.foiservices.com and begin at the search box in the center of the page. Enter a somewhat generic name for your product, in this example, “infrared thermometer” Then click the search button to see a list of device titles which include the phrase “infrared thermometer” somewhere in the descriptive record. Here’s the result of your search: Double-click on any record(s) you find of potential interest for a complete document description. Result is on the next page. Beyond 510(k)s: Researching Other Types of FDA Documents You can use the same technique to search for many other types of unpublished FDA documents. For example, to find Establishment Inspection Reports for a firm enter: “Firm Name” EIR in the search box (the double quotes are used to specify a particular phrase). You can even search on a name – for example, an FDA investigator can be searched by entering: “John Doe” to locate all records including that phrase. Then you can use the resulting documents to help you learn more about a particular FDA investigator’s patterns, habits, and interaction style. Document Types For more information about other kinds of documentation, click on any of the document types under the Click to Search box on the home page. Entering Searches For information about entering special terms such as dates, phrases, FDA submission numbers, etc., click Search Hints on the menu across the top of the home page. Personalized Help We are always happy to help you research a topic or structure a search. For help with your topic, please email [email protected] at any time, or phone +1-301-975-9400 during our operating hours of 9:00am – 5:00pm ET, Monday-Friday. The document details will help you determine if the full file will be helpful to you: Document Title, Page Count & Price Date of Substantial Equivalence Determination FDA Device Number & Classification Code Submission Type (Traditional, Special, Abbreviated) FDA Classification Description Predicate Devices Device Class & 21 CFR Citation Describing the Device Code Submission Date – Compare this with Date of Substantial Equivalence Determination Above Company Name & Address Persons Involved with the Submission Contents of this Document All of the information up to this point has been free. If you want the complete document, add it to your shopping cart, check out and the document can be immediately downloaded in PDF format – no waiting for FDA to respond to your FOIA request. Need More Help in Finding FDA Documents? While we don’t have every FDA document ever prepared, our collection is very extensive. If you need more information, give us a call or send us an email; our information specialists are always happy to help you. This process offers you important benefits, including: 1) easy access to the most complete 510(k) documentation available to help you identify predicates, learn about competitors’ products and their 510(k) experiences, and help develop your own 510(k) 2) the ability to download files instantly rather than potentially wait years for a government response, and 3) maintaining the confidentiality of your research interests - if you place requests with FDA your queries are a matter of public record. FOI Services, Inc. 704 Quince Orchard Road • Suite 275 Gaithersburg MD 20878-1770 USA Phone: 1-800-654-1147 or +1-301-975-9400 Fax: 301-975-0702 Email: [email protected] www.foiservices.com
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